NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

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Page 1 of 27

White Paper

NIOSH Response to SC&A Comments Concerning Part of 

Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley 

National Laboratory

December 4, 2013

Stephen Spanos
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

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Page 2 of 27

Summary: 

As a result of the Lawrence Berkeley National Laboratory (LBNL) Work Group’s (LBNLWG) 

Meeting on February 3, 2012, SC&A reviewed exposure potential from internal emitters at 

LBNL for the post-1961 period to determine their significance and whether bioassay monitoring 

was complete and adequate for that time period. SC&A sampled available dosimetry records for 

pertinent information regarding what exposure potential existed in which operations and 

buildings, and whether monitoring was available and adequate (and addressed in the current 

TBD). This report is a response to those comments. The reader is referred to SC&A’s original 

report for their full text (Draft White Paper: SC&A Review of Lawrence Berkeley National 

Laboratory Site Profile Matrix Issue #2, September 2012).

SC&A reviewed post-1961 records available in the Site Research Database (SRDB), evaluated 

dosimetry program documentation and dose information, and compared its assessment with that 

provided in the TBD. SC&A indicated apparent gaps and differing assessments of bioassay 

program adequacy in their review, with an emphasis on what programmatic or dosimetric 

shortcomings would have the most significant influence on dose reconstruction.

SC&A’s review under site profile Matrix Issue #2 raised two central questions for Work Group 

consideration: 

1. Exposure potential posed by radionuclide source terms for which adequate bioassay 

monitoring may be lacking (or which are not addressed by the TBD), making sufficiently 

accurate dose reconstruction problematic; and

2. Inadequate management of the bioassay program at LBNL making bioassay results less 

reliable for use in dose reconstruction.

For question (1), SC&A questioned how LBNL could have adequately monitored for short-lived 

Mixed Activation Products (MAPs) using in vitro gross alpha and beta techniques, coupled with 

whole-body counting (WBC), when MDA detection thresholds and extended monitoring periods 

would have mitigated against detection. 

For question (2), SC&A indicated that NIOSH has accepted the inauguration of the LBNL 

bioassay program in 1961 as the threshold of a comprehensive and reliable program for internal 

dosimetry (and therefore the end of the SEC-covered period), while SC&A believes pertinent 

program documentation (e.g., DOE audits in the 1980s) clearly highlight persistent inadequacies 

in how the program was managed that bear directly on data reliability.
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

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Based on information in the Discussion section below, NIOSH has determined that based on a 

review of pertinent literature, and LBNL accelerator air sample data , short-lived MAPs, such as 

C-11, N-13, and O-15, produced in LBNL accelerators were not a radiological concern.

NIOSH has determined during site research and the SEC evaluation that LBNL had an 

operational bioassay monitoring program in 1962. Numerous documents and memos discussing 

the program lead to conclusion that all individuals who worked with uncontained radioactive 

materials were monitored for intakes of radioactive material, and that their individual bioassay 

results can be used to assess their internal dose. 

Discussion: 

Issue 2: Insufficient information for internal dose reconstruction, especially during the

early years

This issue involves SC&A comments concerning the following:

1. Mixed Activation Products;

2. Adequacy of Gross Alpha Urinalysis Procedure; and

3. Fecal Bioassay versus Urinalysis Bioassay.

I. NIOSH response to SC&A’s comments regarding exposure potential for which adequate 

bioassay coverage may be lacking:

Mixed Activation Products (MAPs):

SC&A categorized the MAPSs above as C-11, N-13, O-15, Ar-41, Be-7, and others. 

Various reports and studies have been conducted concerning airborne radioactivity at high 

energy accelerators. Two reports are Airborne Radioactivity Produced at High Energy 

Accelerators (Rindi 1967), and Aerosol and Dust Radioactivity in the Halls of High Energy 

Accelerators (Charalambus 1967). These reports, as well as others, have been the basis for 

categorizing the airborne radionuclides of inhalation concern at high energy accelerators. The 

findings and conclusions from these reports have been summarized in Accelerator Health 

Physics (Patterson 1973).

Airborne radioactivity inhalation concerns at high energy accelerators result from activated gases 

and activated dust and aerosols (Rindi 1967, Charalambus 1967).
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

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or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

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During accelerator operation radioactive gases are produced by the interaction between the 

primary and secondary particles from the machine and the atmospheric air in the accelerator 

halls. Spallation reactions in solid machine parts can also lead to the formation of radioactive 

gases (Rindi 1967).

Radioactive dust is produced from activated machine parts by normal erosion or mechanical 

wear. Dust in the accelerator halls is also activated when it is in suspension in the air or when it 

is deposited on the machine components. However, experience shows that the principal 

radioisotopes found in dust are those produced from the constituents of the machine parts

(Charalambus 1967).

Lists in various documents of radionuclides that can be produced in air at accelerators vary as to 

the number presented based on the reactions that form them. A list of radionuclides with halflives greater than 10 minutes that can be produced in air at accelerators is shown in Table 1. 

This is based on a list from Thomas (1978).

Table 1. Radionuclides with Half-life > 10 Minute that can be Produced in Air at Accelerators*

Radionuclide Half-Life Emission Parent 

Element

Production 

Reaction

H-3 12.2 years β- C Spallation 

N Spallation 

O Spallation 

Be-7 53 days γ, EC C Spallation 

N Spallation 

O Spallation 

Ar Spallation 

C-11 20.5 min β+ C Spallation 

N Spallation 

O Spallation 

Ar Spallation 

F-18 1.85 hr β+, EC Ar Spallation 

Na-22 2.6 years β+, γ Ar Spallation 

Na-24 15 hr β- Ar Spallation 

Mg-28 21.3 hr β-, γ Ar Spallation 

Al-28 2.3 hr β-, γ Ar Spallation 

Si-31 2.6 hr β-, γ Ar Spallation 

P-32 14.3 days β- Ar Spallation 
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

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or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

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P-33 25 days β- Ar Spallation 

S-35 87 days β- Ar Spallation 

Cl-34m 32.4 min β-, γ Ar Spallation 

Cl-38 37.3 min β-, γ Ar (γ, pn) 

Cl-39 55 min β-, γ Ar (γ, p) 

Ar-41 1.8 hr β-, γ Ar (n, γ)

* Pertinent data excerpted from Thomas 1978.

Argon-41 is an inert gas and not considered an internal hazard, but an external hazard determined 

via immersion in the radioactive cloud. Nuclides with half-lives less than 10 minutes are also 

not considered internal exposure hazards because there is insufficient time for the material to be 

distributed to the organs.

Accelerator Health Physics indicates that the gaseous airborne radioactivity concentrations 

measured are of extremely short duration after accelerator turnoff, because of the short half-lives 

of the important nuclides and dilution with inactive air (Patterson 1973). Also, workers are not, 

in general, continuously exposed to short-lived gaseous airborne radioactivity produced in 

accelerators for 40 hours per week.

The same reference indicates regarding accelerator-produced gaseous airborne radioactivity that, 

“long-lived activities, on the other hand, may be discounted because of their low production rate. 

In usual facilities, where complete air changes occur 2 to 3 times per hour, even normal leakages 

may amount to 10% of the volume of enclosed air per hour. Unless special steps are taken to 

prevent air from leaving the accelerator room its residence time is considerably less than 1 day. 

It is not possible, therefore, to produce Be-7 or H-3 at levels higher than a small fraction of 

saturated specific activity.”

The conclusions of several studies have shown that the potential exposure from radioactive dust 

is negligible (Patterson 1973). The most frequently identified radionuclides in dust at a high 

energy proton accelerator were Mn-54, Be-7, Cr-51, Fe-59, and V-48, and are shown in Table 2

(Patterson 1973). Mn-54, Cr-51, Fe-59, and V-48 are produced in the accelerator magnets, and 

vacuum chambers (Charalambus 1967). Be-7 can be produced in the accelerator coils 

(Charalambus 1967), as well as activation of air. 

Table 2. Radionuclides Identified in Dust Samples at CERN Proton Synchrotron (after 

Charalambus and Rindi) (Patterson, 1973)

Radionuclide Decay Mode Relative Quantity 

(%)
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

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or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

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Mn-54 EC, γ ~50

Be-7 EC, γ ~25

Cr-51 EC, γ ~7

Fe-59 β+, γ ~9

V-48 β+, γ ~9

An essentially identical conclusion regarding the potential exposure from radioactive dust has 

been reached by studies at the Saclay electron linac operating at high power (330 to 560 MeV, 

100 kW on target) (Patterson 1973).

The above list (Table 2) of radionuclides identified in dust samples at CERN (Charalambus

1967) contains only a small fraction of radionuclides that can be produced in the principal 

materials of the accelerator. A list of the main radionuclides that can be produced by the 

interaction of primary and secondary particles from a high-energy proton accelerator with the 

principal materials (shielding, magnets, coils and vacuum chamber) in the machine are shown in 

Table 3 (Charalambus 1967).

Table 3. Main Radionuclides Produced by the Interaction of Primary and Secondary Particles 

from a High-Energy Proton Accelerator with the Principal Materials in the Machine

(Charalambus 1967)*

Radionuclide Half-life Decay 

Mode

Parent Isotope 

(machine part)a Type of reaction

Na-22 2.6 y β+, γ Na-23(S) (n,2n) 

Na-23(S) (p,pn) 

Na-23(S) {p,pn) 

Mg-24(S) (p,2pn) 

Al-27(M) (p,spallation) 

Ca-40(S) (p,spallation) 

Fe-56(M) (p,spallation) 

Co-60 5.2 y β-, γ Co-59(M) (n,γ) 

Ni-59(M) (n, p) 

Cu-63(M) (n,α) 

Cu-63(M) (p,spallation) 

Cu-63(M) (p,spallation) 

Sc-46 84 d β-, γ Ti-48(M) (p,2pn) 
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

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Page 7 of 27

Radionuclide Half-life Decay 

Mode

Parent Isotope 

(machine part)a Type of reaction

Cr-52(M) (p,spallation) 

Mn-55(M) (p,spallation) 

Fe-56(M) (p,spallation) 

Mn-54 300 d EC, γ Mn-55(M) (n,2n) 

Fe-54(M) (n, p) 

Fe-56(M) (p,2pn) 

(n,p2n)

Fe-59 45 d β-, γ Fe-58(M) (n,γ) 

Co-59(M) (n, p) 

Ni-60(M) (n,2p) 

Cu-63(M) (p,spallation) 

Co-58 71 d EC, β+, γ Co-59(M) (n,2n) 

Ni-58(M) (n, p) 

Ni-60(M) (n,2pn)

Cu(M) (p,spallation) 

Zn-65 245 d EC, β+, γ Cu-65(M) (p,n)

V-48 16.1 d EC, β+, γ Cr-52(M) (p,spallation) 

Mn-55(M) (p,spallation) 

Fe-56(M) (p,spallation) 

Co-56 77.3 d EC, β+, γ Co-59(M) (p,spallation) 

Ni-58(M) (p,2pn) 

Ni-60(M) (p,spallation) 

Cu-63(M) (p,spallation) 

P-32 14.3 d β- P-31(M) (n,γ) 

S-32(S) (n, p) 

K-39(S) (p,spallation) 

Ca-40(S) (p,spallation) 

Fe-56(M) (p,spallation) 

Ca-45 164 d β- Ca-44(S) (n,γ) 

Ti-48(M) (p,spallation) 

Cr-52(M) (p,spallation) 
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

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Radionuclide Half-life Decay 

Mode

Parent Isotope 

(machine part)a Type of reaction

Mn-55(M) (p,spallation) 

Fe-56(M) (p,spallation) 

K-43 22.4 h β-, γ Ca-44(S) (n,pn)

Fe-56(M) (p,spallation) 

K-42 12.4 h β-, γ K-41(S) (n,γ) 

Ca-44(S) (p,spallation) 

Fe-56(M) (p,spallation) 

Mn-52 5.6 d EC, β+, γ Mn-55(M) (p,3np)

Fe-56(M) (p,spallation) 

Na-24 15 h β-, γ Na-23(S) (n,γ) 

Mg-24(S) (n,p)

Al-27(M) (n,α) 

Al-27(M) (p,3pn)

Ca-40(S) (p,spallation) 

Fe-56(M) (p,spallation) 

Sc-48 44 h β-, γ Ti-48(M) (n,p)

Cr-52(M) (p,spallation) 

Mn-55(M) (p,spallation) 

Fe-56(M) (p,spallation) 

Co-57 270 d EC, γ Co-59(M) (p,p2n)

Ni-58(M) (n,pn)

Ni-58(M) (p,2p)

Ni-60(M) (p,spallation) 

Cu(M) (p,spallation) 

S-32 87 d β- K-30(S) (p,spallation) 

Ca-40(S) (p,spallation) 

Fe-56(M) (p,spallation) 

P-33 24.4 d β- K-39(S) (p,spallation) 

Ca-40(S) (p,spallation) 

Fe-56(M) (p,spallation) 

Sc-47 3.4 d β-, γ Ti-48(M) (n,pn)
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

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Page 9 of 27

Radionuclide Half-life Decay 

Mode

Parent Isotope 

(machine part)a Type of reaction

Cr-52(M) (p,spallation) 

Mn-55(M) (p,spallation) 

Fe-56(M) (p,spallation) 

Ni-65 2.6 h β-, γ Ni-64(M) (n,γ) 

Cu-65(M) (n,p)

Mn-56 2.6 h β-, γ Mn-55(M) (n,γ) 

Fe-56(M) (n,p)

Fe-57(M) (n,pn)

Fe-55 2.6 y EC Fe-54(M) (n,γ) 

Fe-56(M) (n,2n) 

Mn-55(M) (p,n)

Co-59(M) (p,spallation) 

Si-31 2.6 h β-, γ Si-30(S) (n,γ) 

P-31(M) (n,p)

K-39(S) (p,spallation) 

Ca-40(S) (p,spallation) 

Fe-56(M) (p,spallation) 

Cu-64 12.9 h EC, β+, β-, γ Cu-63(M) (n,γ) 

Cu-65(M) (n,2n) 

Cu-63(M) (p,pn) 

Be-7 53 d EC, γ C-12(S (p,spallation) 

O-16(S,M) (p,spallation) 

Na-23(S) (p,fragmentation)

Al-27(M) (p,fragmentation)

Si-28(S) (p,fragmentation)

Ca-40(S) (p,fragmentation)

Fe(M) (p,fragmentation)

Fe(M) (p,spallation) 

Cr-51 27.8 d EC, γ Cr-50(M) (n,γ) 

Cr-52(M) (n,2n) 

Mn-55(M) (p,spallation) 

Fe-56(M) (p,spallation) 
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 10 of 27

Radionuclide Half-life Decay 

Mode

Parent Isotope 

(machine part)a Type of reaction

Ni-57 36 h β+, γ Ni-58(M) (n,2n) 

Ni-60(M) (p,p3n)

Ni-58(M) (p,pn) 

Cu-63(M) (p,spallation)

Mg-28 21.3 h β-, γ Si-29(S) (n,2p) 

Si-30(S) (n,2pn)

P-31(M) (p,spallation)

Ca-40(S) (p,spallation)

Fe-56(M) (p,spallation)

Sc-43 3.9 h β+, γ Ti-48(M) (p,spallation)

Cr-52(M) (p,spallation)

Mn-55(M) (p,spallation)

Fe-56(M) (p,spallation)

Sc-44 2.4 d γ Ti-48(M) (p,3p3n)

Sc-44 4 h β+, EC, γ Cr-52(M) (p,spallation)

Mn-55(M) (p,spallation)

Fe-56(M) (p,spallation)

Ti-45 3.1 h EC, β+ Ti-46(M) (n,2n) 

Cr-52(M) (p,spallation)

Fe-56(M) (p,spallation)

V-49 330 d EC Cr-50(M) (n,p)

Cr-52(M) (p,2p2n)

Mn-55(M) (p,spallation)

Fe-56(M) (p,spallation)

Co-55 18 h β+, γ Co-59(M) (p,3p3n)

Ni-58(M) (p,2pn) 

Ni-60(M) (p,spallation)

Cu-63(M) (p,spallation)

a - (S) = shielding, (M) = magnets, coils, and vacuum chambers.

* Pertinent data excerpted from Charalambus 1967.
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

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Page 11 of 27

LBNL recognized the issue of short-lived MAPs early on in its accelerator programs. LBNL 

indicated that for the 60-inch and 184-inch cyclotrons, “From the health hazard viewpoint we 

feel that the situation is, under existing beams and energies, marginal and readily controllable by 

existing exhaust ventilation” (Thaxter 1961). The same report indicated that the C-11, N-13, and 

O-15 combined maximum air concentration in the 184-inch cyclotron was approximately 2x10-7

μCi/cm3

, and were below MPC. Since N-13 and O-15 have half lives less than 10 minutes, C-11 

is the only measurable radionuclide of concern for internal exposures. Carbon-11 was 

approximately 25 percent of the total activity measured (Thaxter 1961). This results in a 

maximum C-11 air concentration of approximately 5.0x10-8 μCi/cm3

, and is approximately 40 

times less than its MPCa of 2x10-6 μCi/cm3

. The C-11 maximum air concentration of 5.0x10-8

μCi/cm3 yields a maximum dose of approximately 1 mrem, using the limiting ICRP 68 dose 

conversion factor for the pancreas of 8.89x10-3 mrem/μCi, and a breathing rate of 2400 m3/yr (40 

hours per week for 50 weeks per year). The 1 mrem dose is conservative, given that the 

maximum level of C-11 inhaled is assumed to be constant, and a worker would not be expected 

to be exposed to this level for 40 hours per week. In addition, dilution from ventilation, 

radioactive decay, and accelerator off time would reduce the C-11 dose to less than 1 mrem. The 

60-inch cyclotron maximum air concentrations approached 1x10-9 μCi/cm3 for N-13, N-16 and 

O-15 measured, and were well below MPCa guides. N-13, N-16 and O-15 all have half- lives 

less than 10 minutes. 

The 88-inch cyclotron minimized the possibility of contamination by means of airborne 

radioactivity by forced-air ventilation at negative pressures of the cyclotron vault and pit areas. 

Filtered high-bay air is pulled by blower through the vault floor and roof, and is then ducted from 

the cyclotron pit area to a monitored exhaust in the updraft of the water cooling tower (LBNL 

1979).

Bevatron safety procedures indicated that both sources of airborne radionuclides were 

recognized at the accelerator (gaseous isotopes produced in air and vented gases as well as

airborne radioactive dust) as a result of thermal neutron capture, high-energy particle spallation, 

and (gamma, n) reactions. Due to relatively low average beam and methods of beam transfer, 

i.e., in vacuum, the yield from either mode at the Bevatron is small compared to MPC guides 

(Everette 1976).

A review was conducted of available LBNL accelerator air sample data for several years. The 

results of these air samples, along with dose estimates using the limiting ICRP 68 dose 

conversion factor, are shown in Table 4. The doses assume continuous occupancy for 40 hours

per week and 50 weeks per year. As indicated previously, workers are not, in general, 

continuously exposed to short-lived gaseous airborne radioactivity produced in accelerators for 

40 hours per week. As can be seen from the results, and accounting for intermittent exposure, all 
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

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Page 12 of 27

the doses are less than 1 mrem. A limited review of various air sample report notations also 

indicate that the beta and gamma activities measured were much less than 1% of the MPC or 

DAC. Based on a review of available air sample data, NIOSH believes that the beta and gamma 

activities in the LBNL accelerators likely constitute a very small, if not negligible, internal dose 

potential. 

The Health Chemistry Department, which later became part of the Environmental Health and 

Safety Department, maintained strict control of the movement of radioactive materials at LBNL. 

They maintained a stock of target holders, inspected and leak-tested the loaded target holder, and 

delivered it to the accelerator when satisfactory, operated the bombardment apparatus at the 88-

inch cyclotron, and delivered the bombarded target to the experimenter and assisted with 

disassembly (UCRL 1964).

The use of glove boxes for the handling of dispersible radioactive material was the policy early 

on at LBNL. Work enclosures, including glove boxes, constituted the basic component for 

handling large or small quantities of the various types of radioactive materials at LBNL (Garden 

1960). Environmental Health and Safety Department procedures indicated that ventilated gloved 

boxes were to be used for all radioactive operations that could generate aerosols, or the possible 

spread of contamination (EH&S 1981). The glove box use requirement for dispersible 

radioactive material is also indicated in various accelerator operational safety procedures, some 

of which are cited below.

Along with target handling control at LBNL, the accelerator target rooms and laboratories that 

handled radioactive materials by design were at negative pressure (UCRL 1964), thereby 

preventing outflow of any potential airborne activity releases into the surrounding areas. 

Enclosing targets in a sealed target holder and ventilation flow control was necessary in 

accelerator facilities to prevent contamination of the experimental cave areas, as well as the 

accelerator machine.

Various Operational Safety Procedures (OSPs) for the LBNL accelerators; Bevatron/Bevalac, 

SuperHILAC, 184 inch cyclotron, and 88 inch cyclotron, indicate that access to the cave areas 

where the targets were bombarded, as well as the accelerator machine were controlled by safety 

interlocks to prevent accidental exposure (LBL 1972, 1979, 1982, 1984). 
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, 

and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document 

represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Page 13 of 27

Table 4. LBNL Accelerator Air Activity Concentration Information (LBL 1965, LBL 1967, LBL 1975, LBL 1988, EH&S 1995)

Year Location Radionuclide

Activity

(pCi)

Activity 

Concentration

(pCi/m3) Half Life

ICRP 68 

Maximum

Organ DCF

(mrem/pCi)

Dose to 

Maximum

Organ2

(mrem)

ICRP 68 

Maximum 

Organ

1965 Building 51 

(Bevatron) 

NDT

Be-7 20000 20 53.3 d 1.56E-06 7.49E-02 ET

Na-24 20000 10 15.0 h 4.81E-05 1.15E+00 ET

P-32 1500 1.5 14.29 d 5.93E-05 2.13E-01 Lungs

3 day T1/2 1500 1.5

1965 Building 6 

Platform

Be-7 -- 30 53.3 d 1.56E-06 1.12E-01 ET

(184 inch 

Cyclotron)

P-32 -- 1.8 14.29 d 5.93E-05 2.56E-01 Lungs

1987 88 inch 

Cyclotron 

Caves

Cave 3 Be-74 -- 240 53.3 d 1.56E-06 8.99E-01 ET

Cave 2 Be-74 -- 22 53.3 d 1.56E-06 8.24E-02 ET

Cave 4C Be-74 -- 16 53.3 d 1.56E-06 5.99E-02 ET

RAMA Be-74 -- 18 53.3 d 1.56E-06 6.74E-02 ET
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, 

and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document 

represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Page 14 of 27

Year Location Radionuclide

Activity

(pCi)

Activity 

Concentration

(pCi/m3) Half Life

ICRP 68 

Maximum

Organ DCF

(mrem/pCi)

Dose to 

Maximum

Organ2

(mrem)

ICRP 68 

Maximum 

Organ

1988 88 inch 

Cyclotron High 

Level Cave

Sr-89/Y-89m 1000 1 50.5 d 2.52E-05 6.05E-02 Bone Surface

Tc-96 1000 1 4.28 d 6.67E-05 1.60E-01 ET

Y-87/Sr-87m 600 0.6 80.3 h 2.33E-05 3.36E-02 ET

Ru-97 700 0.7 2.9 d 9.26E-06 1.56E-02 ET

Mn-52 40 0.04 5.591 d 8.89E-05 8.53E-03 ET

1989 88 inch 

Cyclotron 

E.AL-2

Ce-144 120 0.12 284.3 d 8.15E-04 2.35E-01 Lungs

Eu-152 30 0.03 13.33 y 6.67E-04 4.80E-02 Liver

Ba-133 15 0.015 10.74 y 3.56E-05 1.28E-03 Bone Surface

Mn-54 Trace Trace 312.5 d 2.70E-05 Trace ET

1990 88 inch 

Cyclotron 

E.AL-24

Co-57 300 0.15 270.9 d 1.37E-05 4.93E-03 Lungs

Se-75 100 0.05 119.8 d 2.78E-05 3.34E-03 Kidneys

Mn-54 100 0.05 312.5 d 2.70E-05 3.24E-03 ET

Zn-65 3500 1.75 243.9 d 2.74E-05 1.15E-01 ET

Na-22 1000 0.5 2.602 y 7.41E-05 8.89E-02 ET

Co-60 40 0.02 5.271 y 3.56E-04 1.71E-02 Lungs
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

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and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document 

represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

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Page 15 of 27

Year Location Radionuclide

Activity

(pCi)

Activity 

Concentration

(pCi/m3) Half Life

ICRP 68 

Maximum

Organ DCF

(mrem/pCi)

Dose to 

Maximum

Organ2

(mrem)

ICRP 68 

Maximum 

Organ

Co-58 300 0.15 70.80 d 3.52E-05 1.27E-02 ET

Co-56 Trace Trace 78.76 d 1.07E-04 Trace ET

Unidentified 

alpha

250 0.25

1990 88 inch 

Cyclotron High 

Level Cave

Be-7 43 0.43 53.3 d 1.56E-06 1.61E-03 ET

Na-22 40 0.04 2.602 y 7.41E-05 7.11E-03 ET

Co-57 17 0.017 270.9 d 1.37E-05 5.59E-04 Lungs

Mn-54 Trace Trace 312.5 d 2.70E-05 Trace ET

Co-60 Trace Trace 5.271 y 3.56E-04 Trace Lungs

Se-75 Trace Trace 119.8 d 2.78E-05 Trace Kidneys

Co-58 Trace Trace 70.80 d 3.52E-05 Trace ET

Zn-65 370 0.370 243.9 d 2.74E-05 2.43E-02 ET

1990 88 inch 

Cyclotron High 

Level Cave

Be-7 80 0.08 53.3 d 1.56E-06 3.00E-04 ET

Ta-182 12 0.012 115 d 1.96E-04 5.64E-03 Lungs

1 – Some air sample results were in pCi activity only. The air sample volume assumed is 1000 cubic meters based on the 1988 88-inch Cyclotron High Level 

Cave one week air sample. This is also found in a notation for the 1965 Bevatron one week air sample listed in the above table (LBL 1967). The 4 cubic feet 

per minute air sampler flow rate is also confirmed based on EH&S information on air sampling [EH&S 1981]. Four cubic feet per minute corresponds to a 1 
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

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and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document 

represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

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Page 16 of 27

week sample volume of 1142 cubic meters. All activities that were converted to activity concentrations in the table for 1989 and later are based on the 

nominal air sample volume of 1000 cubic meters.

2 – Breathing rate of 2400 cubic meter of air inhaled per work year assumed based on 40 hours per week and 50 weeks per year.

3 – Two week air sample was indicated for this result (EH&S 1995) The activity results are divided by 2000 cubic meters.

4 – Air sample report notation indicates that the activity is mostly Be-7.
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 17 of 27

Targets required cooling times and were surveyed prior to removal and transport from the cave 

target area to prevent external dose overexposure. In addition, the various accelerator OSPs 

required ventilated gloved boxes to be used for all radioactive operations that generate aerosols 

or cause possible spread of contamination or significant personnel exposure. Gloved box passouts and pass-ins were required to be done with the assistance of an EH&S Department monitor

(EH&S 1981).

Health Chemistry maintained a supply of air samplers in locations where accidental releases of 

airborne radioactivity was likely (UCRL 1964). Health Chemistry also maintained permanently 

installed air samplers which operated continuously in various locations. The air samples were 

changed weekly in locations of moderate experimental activity, and daily in locations of intense

experimental activity. Glove box manifolds and rooms that contained glove boxes were air 

sampled. 

SC&A cited a 1968 LBNL Report of the Bioassay Program (LBL 1968) that indicated that 

positive gross beta urinalysis for a survey of 85 accelerator workers was in the range of 1-42 

pCi/24 hour sample, and that these levels were comparable to elevated beta activity in samples of 

surveyed residents in the San Francisco Bay Area. The 1968 Report of the Bioassay Program 

indicated that urine bioassay results of San Francisco residents ranged between 5 to 20 pCi/24h 

of beta activity. 

SC&A interpreted the 1968 Report of the Bioassay Program to mean: “It is likely that short-lived 

MAPs contributed to this constant low-level beta component (particularly with the finding in 

LBL 1968 that was unlikely due to Sr-90), but lack of detection and discrimination due to WBC 

sensitivity and delay in monitoring made it unlikely that these would be picked up, and this 

survey “finding” apparently was the reason LBNL chose not to resolve this unknown exposure 

source term.”

The 1968 Report of the Bioassay Program (LBL 1968) states regarding the above, “It has been 

concluded that the presence of gross beta activity in urine during this time was common to all 

residents of the Bay Area, and that it was due to environmental contamination.” It therefore 

appears that LBNL concluded that the unknown exposure was due to environmental exposures. 

It is not clear to NIOSH how a “lack of detection and discrimination due to WBC sensitivity and 

delay in monitoring” would have resulted in comparable gross beta results between LBNL 

accelerator employees and bay area residents.

A review of gross beta urinalysis bioassay reports through the mid 1970’s showed notations on 

the results which appear to indicate that the elevated gross beta activity levels detected in urine 

samples are from environmental sources including fallout (LBNL 1961):
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 18 of 27

“GROSS BETA" ACTIVITIES FROM 5 TO 80 DPM PER 24 HOUR URINE COLLECTION FROM 

WHICH 40-K AND 137-CS HAVE BEEN REMOVED ARE COMMONLY OBSERVED DUE TO 

ENVIRONMENTAL SOURCES INCLUDING FALLOUT AND ARE NOT NECESSARILY INDICATIVE 

OF OCCUPATIONAL EXPOSURE.”

The Bioassay Laboratory Manual of Procedures (Buckley 1969) included a similar statement 

regarding gross beta activities. Gross beta notations on bioassay reports from the later 70’s and 

beyond contained the following similar notation:

“GROSS BETA" ACTIVITIES UP TO 20 DPM PER 24 HOUR URINE COLLECTION FROM WHICH 

40-K AND 137-CS HAVE BEEN REMOVED ARE COMMONLY OBSERVED DUE TO 

ENVIRONMENTAL SOURCES INCLUDING FALLOUT AND ARE NOT NECESSARILY INDICATIVE 

OF OCCUPATIONAL EXPOSURE.”

A 1969 Health Physics Journal article titled, “Whole-Body Counting and Bioassay 

Determinations Made on Accelerator Workers” provided a peer reviewed article regarding the 

study of the LBNL accelerator workers mentioned above (HPS 1969). The conclusions of the 

article regarding the internal assessments performed on the accelerator workers was, 

“Accelerator workers who have been studied in this survey show the following incidence of 

radioactive contamination: alpha (confirmed) 4%, gamma (by whole-body count) 6%, beta 94%. 

It is believed that the high incidence of beta activity represents environmental contamination. 

The levels of activity found do not exceed 1 pCi per 24-hr urine for alpha emitters, and 10 nCi 

per whole-body count for gamma activity. Accordingly, no changes in existing procedures are 

contemplated as a result of this survey, since it seems evident that normal habits of cleanliness 

and occasionally the use of protective clothing and gloves are adequate to insure that the 

ordinary accelerator worker at LRL-Berkeley will not receive radiation exposures of any 

consequence from internal sources. Nevertheless, it is believed that periodic surveys of the type 

reported herein have value in helping to maintain safe working conditions and in bringing to 

light any unsuspected instances of possibly significant contamination of workers.”

Despite the incidence of some low-level internal beta contamination found, the conclusion was 

that the lower internal burden found in personnel working with the newer accelerators at LBNL

indicated great improvement in operational procedures. The observation of zero or low body 

burdens in the people indicated adequate standards of cleanliness in working conditions and 

personal hygiene of accelerator personnel. The above notations and references indicate that 

LBNL had determined that the gross beta urinalysis results in the range discussed in the 1968

LBNL Report of the Bioassay Program, as well as those in subsequent bioassay report results for 

the site, were from fallout and environmental sources. 
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 19 of 27

In addition, various procedures and requirements were cited earlier for target handling, 

accelerator cave safety interlocks, radioactive materials transport, and radioactive materials 

controls in using glove boxes and enclosures for dispersible radioactive material, negative 

ventilation flow in areas that handled dispersible radioactive material, and air sampling where 

accidental releases of airborne radioactivity was likely. This information indicates that LBNL 

had a strong operating philosophy of containing and minimizing the potential of airborne 

radioactivity in the work environment. Given the sealed target holder, target disassembly in a 

glove box and handling of dispersible radioactive material in a glove box, any short-lived 

radioactive material that may have been created in the accelerator target during bombardment 

would be contained in the ventilated glove box, making the potential for internal exposure 

remote. In addition, LBNL’s policy was to bioassay individuals who worked with or around 

dispersible radioactive materials. Various accelerator airborne radioactivity studies indicate that 

airborne radioactivity produced at high energy accelerators from activated gases, including shortlived MAPs and activated dust and aerosols were not a radiological concern. Furthermore, it is

believed based on a review of LBNL accelerator air samples activity results, that the internal 

dose potential from mixed activation products at LBNL’s accelerators is very small, if not 

negligible.

Adequacy of Gross Alpha Urinalysis Procedure:

SC&A Issue:

For alpha emitters, in general, SC&A had raised questions in its site profile review about how the 

TBD “does not discuss the fact that many radionuclides present at LBNL would not have been 

detected by gross measurements, or at least detected with low recoveries and resulting high 

MDCs [MDAs]... the potential missed dose associated with non-specific bioassay techniques 

should be further investigated to determine the impact on internal dose calculations” (SC&A 

2010). 

NIOSH Response:

The bioassay procedures manual (LowBeer 1964) gross alpha method indicates that, “The

method is applicable to thorium, plutonium, actinium, americium, curium, neptunium, 

californium, and einsteinium.” There were also separate bioassay procedures for uranium, 

radium, and polonium (LowBeer 1964).

Fecal Bioassay versus Urinalysis Bioassay:

SC&A Issue:

SC&A cites a report (LBL 1968), where fecal analysis confirmed uptakes that urinalyses and 

WBCs missed. SC&A also indicates that given the laboratory’s sparing use of fecal analysis 

confirmation (typically only used following an incident), it can be concluded that substantial 
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 20 of 27

missed alpha dose may have existed at LBNL, for which NIOSH’s bounding method may not be 

adequate. As recommended in its 2010 site profile review, SC&A believes the magnitude of this 

missed dose should be assessed in the context of actual monitoring results, such as those cited 

above, and the basis for the TBD revisited in this regard.

NIOSH Response:

The noted fecal samples were collected in response to known incidents; this is common 

procedure for many bioassay programs. Fecal samples can be much more sensitive than urine 

samples if collected shortly after an intake, but later samples (usually within a week to 10 days) 

will be less sensitive. They are not necessarily more reliable or superior for assessing an intake, 

particularly if not linked to a known intake date; urine sample results are less subject to variation. 

Missed dose can be based on the urine samples, with associated MDAs, from the routine 

bioassay program.

 

II. NIOSH Response to SC&A’s Comments Regarding Programmatic Issues Affecting 

Adequacy of Bioassay:

This issue involves SC&A comments concerning the following:

1. Compliance with LBNL bioassay submission requirements; and

2. Program reliability: Selection of personnel and radionuclides.

Compliance with LBNL Bioassay Submission Requirements:

SC&A Issue:

SC&A cites several LBNL Bioassay Program Laboratory reports indicating that delinquent 

samples were an issue. It also cited a 1987 DOE audit about delinquent samples regarding the 

LBNL bioassay monitoring program. 

NIOSH Response:

Late bioassay submittals do not necessarily mean that the bioassay information would be missing 

from a worker’s DOE records received for processing a worker’s claim, unless the sample result 

is completely missing. Delinquent bioassay samples were followed up with notifications to the 

worker in question and generally delinquent bioassay samples were collected from individuals 

(Low-Beer 1960, LBNL 1985). Also, a LBNL 1983 internal audit of the bioassay lists 

concerning delinquent samples indicated, “Each month 10 - 20 requests for samples are sent out 

by (Name Redacted). After a few weeks, if a sample is not returned, a follow up letter is sent. 

After about five weeks of no response, a list showing delinquent samples is sent to (Name 

Redacted) and the ASC's for follow up. From February to July 1983, about 96% compliance 
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 21 of 27

was achieved (Young 1983). Copies of individual bioassay results were distributed to their 

medical file, and Safety Services (Hartsough 1974).

Program Reliability: Selection of Personnel and Radionuclides:

SC&A Issue:

SC&A cites LBNL reports and memoranda from the 1960s through the 1990s that point to a 

management system and culture that would have mitigated against a comprehensive personnel 

selection process addressing what can be a constantly changing experimental work environment 

involving a myriad of different radionuclide sources with exposure potential. The adequacy and 

completeness of LBNL’s bioassay data bear directly on whether potentially exposed employees 

were properly identified and enrolled for bioassay sampling, along with the identity of 

radionuclides to which they may have been exposed. Coupled with the historic lack of 

compliance by employees and lack of enforcement by management, and the lack of quality 

assurance performance checks, the degree of adequacy and completeness of bioassay data is

uncertain, at least until the early to mid-1990s, when more formal management systems were put 

into place at LBNL. SC&A also referred to a 1985 DOE audit of LBNL, citing a laundry list of 

items.

NIOSH Response:

Based on a review of the LBNL’s bioassay program information, NIOSH maintains that LBNL 

had an operational bioassay monitoring program since 1962 and individuals who worked with 

uncontained radioactive materials were internally monitored, and their individual bioassay 

results are available and can be used to assess their internal dose. The pre-1962 era was 

recommended as an SEC based on the absence of an internal dose program and available records. 

Generally, sources in the SRDB indicate that there was a considerable management commitment 

to radiation safety, as is evidenced by numerous files containing bioassay lists and discussions of 

who should be monitored (e.g. Grill 1966, Howe 1961). Discussions include whether or not a 

given worker worked with radioactivity or whether he belonged to a group who does. Also,

indications are that area monitoring was relied on to pick up any unforeseen contamination 

incidents that could expose unmonitored workers (e.g. in 1968 an air sample was able to pick up 

a leaking Cm-244 source, which lead to a number of non-routine samples (Soule 1964). LBNL 

maintained air samplers in locations where releases of airborne radioactivity were likely. The air 

samples were changed weekly or daily.

The Health Chemistry Department maintained personnel in key experimental facilities. The 

normally staffed locations were Buildings 1, 3, 19, 8, 70, 70A, 71, 74, and 88 (UCRL 1964). 

When the Health Chemistry Department later became part of the Environmental Health and 

Safety Department (EH&S), it continued to maintain personnel in key experimental facilities. 
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 22 of 27

The normally staffed locations were Buildings 1, 3, 51, 70, 70A, 71, 74, and 88 (EH&S 1981). 

LBNL maintained bioassay lists from the start of the bioassay program to 1996 when the 

bioassay program changed such that personnel were selected for operational bioassay based on 

the radionuclide authorization program and reviews of work performed. Bioassay lists of names

of individuals were supplied by the Health Chemistry Department to the Bioassay Laboratory

(Various 1961-1964). This practice continued when the Health Chemistry Department became 

part of EH&S, providing names of individuals who were to be monitored for intakes based on 

work performed and work location to the Medical Services Department (Haley 1979). 

The bioassay lists included the worker name, their location, and specific bioassay analyses to be 

performed. These lists were updated periodically based on individuals being added and deleted 

from the list. Delinquents were tracked, and notifications sent. Some bioassay lists included the 

types of radionuclides the employee worked with (e.g. LBL 1988). In one bioassay list case 

there is a note that the worker refused to participate in the program. The level of detail compiled 

in those lists indicates that bioassay analyses were not taken lightly and that management was 

dedicated to the program.

LBNL also provided bioassay reports containing statistics as to how many particular bioassays 

were performed during the period, number of negative results, number of positive results, result 

ranges, and list of individuals who were not sampled (Unknown 1980).

A review of present LBNL claims at the time of this research (February 2013) indicates internal 

monitoring for various job descriptions and supports that LBNL monitored workers across varied 

job disciplines based on exposure potential. Their bioassay program selection process is

described in “NIOSH Evaluation of the Internal and External Monitoring Programs at the 

Lawrence Berkeley National Laboratory”.

Regarding the 1985 DOE audit, LBNL responded to the findings in the 1985 audit (Krebs 1985). 

The audit recommendations and LBNL responses are presented below:

Recommendation 1: Laboratory management assess the effectiveness of the methods used 

within each Division to identify and correct existing or potential safety problems. Corrective 

measures are to be identified, as appropriate, and remedial actions taken.

LBL Response: A copy of the appraisal report has been forwarded to all Division Heads for 

their information, with a request that they review the procedures within their own Division and 

report their findings to the Director's Office by 1st September 1985.

In addition, the Safety Review Committee has agreed to carry out a review of management 

implementation of Laboratory health and safety policies throughout the Laboratory and report 
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 23 of 27

back to the Director, also by 1st September. It is expected that this review report will make 

recommendations to the Director.

Recommendation 2: An overall radiation safety training plan be written and implemented by the 

Laboratory. 

LBL Response: The Radiation Physics Group of the Environmental Health and Safety 

Department are currently engaged in writing an overall radiation safety training plan. This is 

being done in conjunction with the Program Divisions and is expected to be completed by the 

31st of May.

Major sections of this plan exist and include an Introductory Radiological Protection course; XRay Safety Training; Radiological Protection in Chemistry Laboratories. In addition, the 

Laboratory has introduced Supervisors' Training in Safety which deals in general with 

radiological problems; the EH&S Department has trained several technicians for certification by 

the National Registry of Radiation Protection Technologists.

More than 30 scientists and technicians have been trained in radioisotope laboratory radiation 

safety during the first four months of 1985. Radiological Safety Training for members of the 

Bevalac crew took place during April 1985. 

The overall radiation safety training plan and a schedule for implementation will be prepared by 

1st September 1985.

Recommendation 3: The Laboratory review, in approximately six months, the changes to the 

radiation safety program due to the EH&S staffing cuts. The Laboratory provide SAN with an 

assessment of the effect of the staffing cuts on the level of risk.

LBL Response: During October 1985, the Safety Review Committee will prepare for the 

Director an assessment of the impact of staffing cuts made in December 1984 on the radiation 

safety program of the Laboratory. This report will form the basis of a report to DOE/SAN and 

should be prepared no later than 1st November 1985.

Recommendation 4: Provide a comprehensive internal review system. Such a system should 

assign responsibilities for performing the reviews and for implementing, tracking, and follow up 

on corrective actions.

LBL Response: The program adopted by the Safety Review Committee on January 18, 1985, 

assigns overall responsibility for the conduct of internal reviews to the Safety Review 

Committee. This responsibility includes establishing and monitoring criteria for the conduct of 
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 24 of 27

audit activities, providing oversight for the process and transmitting audit findings to affected 

Division Heads. Responsibility for carrying out audit activities and follow-up has been delegated 

to the SRC subcommittee.

Under this new system, the SRC has completed an internal review of the Laboratory's Personal 

Dosimetry Program and reviews of the operations of the Building 75 Tritium Facility, and 

Laboratory procurement of toxic materials are currently under way.

Recommendation 5: Officially adopt and implement a formal ALARA program and give routine 

feedback to line management on ALARA effectiveness.

LBL Response: The pilot Laboratory ALARA program as described by the SAN appraisal team 

will be incorporated in the next revision of the Laboratory Health and Safety Manual. This 

revision will clearly set forth duties and responsibilities for the administration of the Laboratory's 

ALARA program.

Recommendation 6: Prepare detailed procedures for conducting surveys.

LBL Response: More detailed procedures than those which already exist are being written. 

Specific information will include instrument to be used, special problems of low energy betaemitters, frequency and techniques of surveys, bioassay etc.

These Procedures will be incorporated into Publication 3000 at the earliest possible revision.

Recommendation 7: Train Laboratory personnel on survey techniques and include' this training 

as part of the Radiation Safety Training Plan (See Recommendation 2).

LBL Response: Already covered in our responses to recommendations 2 & 7.

Recommendation 8: EH&S develop a system to distribute incident reports and trend analyses to 

line managers.

LBL Response: A system to distribute incident reports and trend analyses to line managers has 

been in place for several years. Use of this system has been extended in recent months.

It can be seen from the above that LBNL took audit findings seriously, and made efforts to 

address them.
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 25 of 27

References:

Buckley, 1969, Bioassay Laboratory Manual of Procedures; UCRL-19355; Barbara C. Buckley; 

September 1969; SRDB Ref ID: 118311

Charalambus, 1967; Aerosol and Dust Radioactivity in the Halls of High Energy Accelerators; S. 

Charalambus and A. Rindi; Nuclear Instrumentation and Methods 56. 125 (1967); SRDB Ref ID:

97897

EH&S, 1981, The Environmental Health and Safety Department Operational Guide for the 

Health and Safety Representative; December 1981; SRDB Ref ID: 21984

EH&S, 1995, Radiochemistry Analysis Reports 1968-1995; SRDB Ref ID: 117678

Everette, 1976, Program for Control or Radiation Hazards Caused By Bevatron/Bevalac Beam 

Induced Residual Radioactivity; Wm. L. Everette; BRRS/WE 100; April 22, 1976; SRDB Ref 

ID: 20841

Garden, 1960, Criteria in Glove Box Design, Function & Operation; N. B. Garden, March 1960 

SRDB Ref ID: 21603 

Grill, 1976, Bio-Assay List; R. P. Grill; RPG-82-66; March 3, 1966; SRDB Ref ID: 20804

Haley, 1979, Bio-Assay List; Semi-Annual Review, Memorandum to All Environmental Health & 

Safety Monitors, Jim Haley, 1979; SRDB Ref ID: 20883

Hartsough, 1974, Bioassay Programs; Walter D. Hartsough; August 26, 1974; DC 74-1098; 

SRDB Ref ID: 21012

Howe, 1961, Bioassay Program; P. W. Howe; PWH-248-61; March 17, 1961; SRDB Ref ID:

20569

HPS, 1969, Whole-Body Counting and Bioassay Determinations Made on Accelerator Workers; 

H. Wade Patterson, Anne de G. Low-Beer, Thorton W. Sargent; Health Physics Pergamon Press 

1969 Vol. 17, pp.621-625.

Krebs, 1985, SAN Radiation Safety Appraisal, January-February 1985; Martha Krebs, Lawrence 

Berkeley Laboratory, May 1, 1985; SRDB Ref ID: 21456
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 26 of 27

LBL, 1965, Health Chemistry Department Report of Special Analysis Building 6; SRDB Ref ID:

117302

LBL, 1967, Radiochemistry Analysis Reports 1964-1967; SRDB Ref ID: 117675

LBL, 1968, Lawrence Berkeley Laboratory, Report of the Bioassay Program; UCRL-18588;

July 1967 through June 1968; Anne de G. Low-Beer and Thorton W. Sargent; November 1968;

SRDB Ref ID: 71905

LBL, 1972, Operational Safety Procedures SuperHILAC Building 71 Complex; UCID-3588; 

October 1972; SRDB Ref ID: 20616

LBL, 1975, Results of Health Chemistry Special Analysis; SRDB Ref ID: 117833

LBL, 1979, Operational Safety Procedures 88 Inch Cyclotron Building 88 Complex; UCID3586; October 1979; SRDB Ref ID: 117754

LBL, 1982, Operational Safety Procedures Building 51 Complex Bevatron; PUB-3020; May 

1982; SRDB Ref ID: 117754

LBL, 1984, Operational Safety Procedure: 184-Inch Cyclotron Complex; RBT:182:84; May 

1984; SRDB Ref ID: 21951

LBL, 1988, Lawrence Berkeley Laboratory, Bioassay List by Buildings; February 9, 1988;

SRDB Ref ID: 21430

LBL, 1988, Lawrence Berkeley Laboratory, Radiochemical Assay Reports; 1989; SRDB Ref ID:

72021

LBNL, 1961, Terminated Bioassay Results of Employees with Last Names Beginning with A 

(1961-1983); SRDB Ref ID: 21986

LBNL, 1985, Bioassay Exposure Data and Delinquency Lists; 1973 to 1985; SRDB Ref ID:

117736

LBNL, 1979, Operational Safety Procedures, 88 Inch Cyclotron, Building 88 Complex; UCID3586; October, 1979; SRDB Ref ID: 117845
NIOSH Response to SC&A Comments Concerning Part of Issue 2 Regarding the 

Internal Monitoring Program at the Lawrence Berkeley National Laboratory

- December 4, 2013

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups 

or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical 

support and review contractors) positions unless specifically marked as such. This document represents preliminary positions 

taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

Page 27 of 27

Low-Beer, 1960, Anne Low-Beer Correspondence, 1960 to 1968; Anne de G. Low-Beer; SRDB 

Ref ID: 117742

Low-Beer, 1964, Manual of Routine Procedures Used in the Bioassay Program at LRL Berkeley; 

Anne de G. Low-Beer; June 10, 1964; SRDB Ref ID: 117754

Patterson, 1973, Accelerator Health Physics; H. Wade Patterson, Ralph H. Thomas; Academic

Press, New York and London, 1973; SRDB Ref ID: 79828

Rindi, 1967, Airborne Radioactivity Produced at High Energy Accelerators; A. Rindi and S. 

Charalambus; Nuclear Instrumentation and Methods 47. 227 (1967); SRDB Ref ID: 97970

SC&A, 2010, Review of the NIOSH Site Profile for the Lawrence Berkeley National Laboratory, 

ORAUT-TKBS-0049, Rev. 01, 2007; SCA-TR-TASK1-0002; January 22, 2010

SC&A, 2012, SC&A Review of Lawrence Berkeley National Laboratory Site Matrix Issue #2

Soule, 1964, Bioassay Program; H. F. Soule; HFS-216-64; May 4, 1964; SRDB Ref ID: 20716

Thaxter, 1961, Airborne Radioisotope Activity within 60" and 184" Accelerator Shielded 

Volume; M. Thaxter, A/E Group; August 23, 1961; SRDB Ref ID: 117469

Thomas, 1978, The Radiological Impact of High-Energy Accelerators on the Environment; LBL8101; Ralph H. Thomas; August 1978; SRDB Ref ID: 23081 and 23079 (Part 2 of SRDB Ref 

ID: 23081)

UCRL, 1964, Health Chemistry Procedures for Radioisotope Safety, UCRL-11700, University 

of California, Lawrence Radiation Laboratory, October 13, 1964; SRDB Ref ID: 21531 

Unknown, 1980, Bioassay Annual Report January 1, 1980 - December 31, 1980; SRDB Ref ID: 

32425

Various, 1961-1964, Memorandums on the Bioassay Program; various authors; various dates 

from 1961-1964; SRDB Ref ID: 72126

Young, 1983, Internal Audit - Bioassay Lists; Jensen Young; October 24, 1983; SRDB Ref ID: 

117641